SecProbe.io

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April 15, 2005

Mail Stop 0306

Mr. Roger E. Gower
Chief Executive Officer
Micro Component Technology, Inc.
2340 West County Road C
St. Paul, MN 55113

	RE:	Micro Component Technology, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
		File No. 000-22384

Dear Mr. Gower:

      We have reviewed your filing and have the following
comments.
We have limited our review to matters related to the issues raised
in
our comments.  Where indicated, we think you should revise your
future filings in response to these comments.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2004

Item 9A. Controls and Procedures - Page 29

1. We note your disclosure that "the Chief Executive Officer and
Chief Financial Officer concluded that, as of the evaluation date,
our disclosure controls and procedures are effective in timely
alerting them to the material information relating to us (or our
consolidated subsidiaries) required to be included in our periodic
SEC filings."  The language that is currently included after the
word
"effective" in your disclosure appears to be superfluous, since
the
meaning of "disclosure controls and procedures" is established by
Rule 13a-15(e) of the Exchange Act.  Please revise future filings
to
limit your conclusion to state simply whether the disclosure
controls
and procedures were effective.  However, if you elect to retain
qualifying language in your disclosure, revise so that the
language
is fully consistent with the definition of disclosure controls and
procedures contained in Rule 13a-15(e).
2. We note your disclosure that "there were no significant changes
made in our internal control over financial reporting, or to our
knowledge, in other factors that could materially affect these
controls..."  In future filings, please remove the words
"significant" and " in other factors that could materially
affect",
and revise your disclosure to discuss all changes in your internal
control over financial reporting that have materially affected, or
that are reasonably likely to materially affect, your internal
control over financial reporting, as required by Item 308(c) of
Regulation S-K, as amended effective August 13, 2003.

Note 7. Long-Term Debt - Page F-17

3. We note that there was no beneficial conversion of the notes
payable into common stock.  Supplementally tell us how the
conversion
price was determined and if the conversion price reflected a
discount
from the quoted market price of the stock on the date of issuance.
If so, tell us why a beneficial conversion feature was not
recognized.  Refer to the guidance in EITF 98-5 and 00-27 as
necessary.

*    *    *    *

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
      You may contact Tom Dyer, Staff Accountant, at (202) 824-
5564
or me at (202) 942-1931 if you have any questions.  In this
regard,
do not hesitate to contact Martin James, the Senior Assistant
Chief
Accountant, at (202) 942-1984.

      Sincerely,

							Angela Crane
							Branch Chief

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Mr. Roger E. Gower
Micro Component Technology, Inc.
April 15, 2005
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